I read with interest Dr. Kesselman's post
regarding the new height requirements for AFO's.
We are in complete agreement with Dr.
Kesselman's statement regarding the ultimate
responsibility belonging to the party who bills
Medicare. We also believe that the new policy
article makes little clinical sense and should
be reconsidered in light of a voluminous amount
of scientific literature supporting the efficacy
of the braces commonly used in podiatry and
orthotics and prosthetics today. We are being
asked to operate in a bizarre environment where
two different Medicare contractors are stating
completely opposite positions about how to apply
the new policies. If that weren’t confusing
enough there are two different policy articles
which are currently valid which contain
contradictory information.
Dr. Kesselman’s post might have given PM News
readers the sense that companies who have been
advertising/communicating information regarding
the current AFO conundrum are somehow misleading
readers. We are not certain which advertisers he
was referring to, but as it relates to Langer
and Arizona AFO, nothing could be further from
the truth. Langer and Arizona AFO have had
considerable contact with the Medicare officials
which Dr. Kesselman references in his post. The
responses both from the Senior Medical Director
and the PDAC officials who crafted the new
definitions were presented in the information
that was contained in our advertisement. While
Dr. Kesselman states, in his opinion he does not
agree with the information, I think it is unfair
to suggest that we are not presenting the facts
as we know them to be. We have had many
customers who also called Medicare directly and
were directed to bill as we identified in our
ads. It should be noted that the American
Orthotic and Prosthetic Association (AOPA) is in
agreement with our interpretation of the policy
articles.
Most importantly, it should be noted that we
have offered all podiatrists the option of
making any custom AFO to whatever height
requirement they prescribe. Because each of our
AFO's are 100% custom made it is easy to extend
the height as long as practitioners send in a
cast that is at least as high as their
requirements. Both Langer and Arizona AFO have
always offered higher AFO’s as part of their
product lines. Making braces at these new
heights is something that we have been doing for
decades based upon the prescriptions from our
clients. Since the new policy article has come
out, we have also offered to make our commonly
used shorter AFO’s available in the new higher
versions. It is important that practitioners
avoid any “gimmicks” to get around Medicare
policy. AFO’s need to be fabricated in
accordance with good manufacturing practices and
technical standards in order to comply with the
new policy. Medical necessity requirements are
unchanged and positive patient outcomes should
be the guiding principles for your AFO
prescriptions
It is our belief, based both on the content of
current PDAC and DME MAC policy articles and on
conversations with Dr. Hoover, the DME MAC
Senior Medical Director and others at Medicare,
that Arizona style gauntlets, including our
SAFO's SMO;s PLS's, HAFOs as well as Langer
Gauntlets, should be coded as always. Should
Dr. Kesselman receive confirmatory information
that contradicts this, we will convey this new
information to our customers. It is my hope that
for the benefit of practitioners, patients and
AFO manufacturers that Medicare lowers the AFO
height requirement and maintains the Arizona AFO
type Advisory currently in effect.
Dr. Kesselman and other members of the APMA DME
subcommittee should be commended for their
efforts to fight these new rules and to obtain
clarity in this vitally important area of
podiatric practice.
Jason Kraus – Executive Vice President, Langer
Biomechanics
Don Pierson – Vice President, Arizona AFO
